not exactly. there is a vpid on the channels, meaning there is video. not even subs can get the test channels. when i say the audio is unencrypted, i mean that any fta receiver with an 8psk module can hear the audio. no iks required
there are two tps on 91 that are t8psk, 12282 and 12370
12282 does have some HD channels, MLBH7 (1487) and some test feeds
12370 are simple test feeds.